What is the test for a lobbyist to be barred from making political contributions under section 86200 of the Hatch Act?

A sufficiently compelling governmental interest justifying substantial interference with political rights was also found in CSC v. Letter Carriers (1973) 413 U.S. 548, 93 S.Ct. 2880, 37 L.Ed.2d 796. Upholding the Hatch Act limiting political activity of governmental employees, the court identified three governmental interests that could be harmed if governmental employees could participate publicly in political activities: (1) governmental employment and promotion might depend upon the extent of participation rather than governmental efficiency, (2) the large number [25 Cal.3d 45] of governmental employees might become a huge political machine defeating our democratic processes, and (3) partisan political activity might impair the employee's ability to act fairly without bias or favoritism. (413 U.S. at pp. 564-567, 93 S.Ct. 2880.)

Obviously, the prohibition against lobbyist contributions in section 86200 is a substantial restriction on the lobbyists' freedom of association, and the restriction may be upheld only if the "State demonstrates a sufficiently important interest and employs means closely drawn to avoid unnecessary abridgment of associational freedoms." (Buckley v. Valeo, supra, 424 U.S. 1, 25, 96 S.Ct. 612, 638, 46 L.Ed.2d 659.) The statute fails to meet the test.